4.3.3.10 Full fee. Special rule: progressively exempt goods and rights

Taxpayers subject to the tax due to a personal obligation to contribute who are owners of assets or rights located or that can be exercised or must be fulfilled in a State with which Spain has signed a bilateral agreement to avoid double taxation, by virtue of which said assets are exempt from Spanish tax, but can be taken into account to calculate the tax corresponding to the remaining assets, they must determine the full amount in accordance with the following procedure:

• The value of the exempt assets and rights, determined in accordance with the rules for valuing the tax reduced, where applicable, in the value of the charges, encumbrances and debts corresponding to them that, if said exemption were not mediated, would be considered tax deductible, must be added to the amount of the taxable base, in order to determine the basis for the application of the tax scale.

• Once the resulting fee is obtained, the average tax rate is determined, which is the result of multiplying by 100 the quotient resulting from dividing the fee by the base for applying the tax scale.

• The average rate will be applied exclusively on the taxable base, without including exempt assets and rights, except to determine the tax rate, also called progressively exempt elements.